- What personally identifiable information is collected by RWR or by any third party through our site and/or via our products or services;
- How and why RWR collects this information;
- How RWR uses this information;
- How RWR secures this information;
- With whom RWR may share this information;
- What choices are available to you as a user of the site and/or products and services with respect to collection, use and distribution of the information;
- What types of security procedures are in place to protect the loss, misuse or alteration of information under our control; and
- How you can correct any inaccuracies in the information.
Information Collection and Use
RWR is the sole owner of the information collected on this site or via our products and services. RWR may collect information from you at two different stages. First, we collect anonymous, aggregate information from all visitors to the site and users of our products and services. This information is never linked to any personally identifiable information and is only used in the aggregate to generate statistical reports about the use of our site, products and services. Second, RWR collects personally identifiable information when you create a RWR account or sign up to receive a newsletter, and when you order RWR products or utilize certain services. Account creation may require you to submit the following personal information: name, address, company information, location, email address, and phone number. For purposes of billing, you may need to provide your credit card type, number, expiration date and billing address for the card. RWR may also receive personally identifiable information from our business partners. We retain information for as long as we have a lawful basis to keep it.
Personal Information of Children Under 13
RWR complies with the requirements of the Children’s Online Privacy Protection Act (COPPA) and the FTC’s Rule interpreting COPPA (16 CFR § 512). This site is not directed to children and does not knowingly collect any personally identifiable information from children under 13 years of age.
Use of Your Personal Information
Our primary goal in collecting information from you is to provide you with a smooth, efficient and customized experience while using our site and to allow us to provide products and services to you. RWR will never give your information to, or share your information with, any third party not affiliated with or owned by RWR, except as permitted by law. RWR will send personally identifiable information about you to other companies or people only when:
- We have your consent to share the information;
- We need to send the information to companies who work on behalf of RWR to provide a product or service to you. (Unless we tell you differently, these companies do not have any right to use the personally identifiable information we provide to them beyond what is necessary to assist us); or
- We respond to subpoenas, court orders, or legal process or find that your actions violate RWR Terms of Service or any of our usage guidelines for specific products or services.
We store information that we collect through cookies and log files. Collected information in a profile is tied to the customer’s personally identifiable information. However, your profile is used solely for internal purposes, to help us improve the experience of our customers. We do not share your profile with any third parties.
A cookie is a small text file stored on the customer’s hard drive for an extended period of time. The cookies can be removed by following Internet browser help file directions. Allowing a RWR cookie to remain on your computer makes it easier for you to log in to and use the site.
Log files record internet protocol (IP) addresses, browser types, internet service provider (ISP) referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track a customer’s movement in the aggregate and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information.
In addition, to the extent that RWR is deemed to transfer personal information outside of the European Union under GDPR (as defined below), we will rely on a legal basis to transfer that information, such as the Standard Contractual Clauses adopted by the European Commission and/or the EU-US and certification under the Swiss-US Privacy Shield Frameworks.
If you subscribe to our Belt and Road Monitor newsletter, your information is registered on our Mailchimp account, including: email address, first name and last name. Mailchimp has submitted to the EU-US Privacy Shield, a certification according to the EU-US Data Protection Shield. Further information can be found at: https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active
When you sign up for a paid subscription to the Belt and Road Monitor newsletter, we ask for the information that is legally required for invoicing and supply it directly to Chargebee. We do not store this information in our systems. This information includes: email, first name, last name, affiliation, payment information and address. Please find here Chargebee’s GDPR Compliance regulations.
External Payment Service Providers
(1) We use external payment service providers on our website. We transmit the data entered by you to the payment service providers exclusively for payment processing. The payment service providers process the data of the customers that is required to carry out the transaction (including name, e-mail address, and financial transaction data, such as account data or credit card number). Payment transactions are subject to the terms and conditions and data protection notices of the payment service provider, which is Stripe, Stripe, Inc., 3180 18th Street, San Francisco, CA 94110 USA. We will pass on to Stripe the information required according to this paragraph.
(2) For invoicing we use Chargebee, a service of Chargebee Inc, 340 S Lemon Avenue, 1537, Walnut, California 91789 USA. For this purpose, the billing address, the e-mail address and the name of the invoice recipient are stored. The payment information is stored at Chargebee. Chargebee has submitted to the EU-US Privacy Shield, a certification according to the EU-US Data Protection Shield. Further information can be found at: https://www.privacyshield.gov/participant?id=a2zt0000000TN6jAAG&status=Active.
Disclosure of Personal Information as Required by Law
We will disclose personal information when required by law, or if we have good-faith belief that such action is necessary to (a) comply with current judicial proceedings, a court order or legal process served on us, (b) protect and defend our rights, or (c) protect the rights, property, and other interests of our users or others.
In the event that RWR goes through a business transition, such as a merger, acquisition by another company, or sale of a portion of its assets, our customers’ personal information may be part of the assets transferred. Customers will be notified via prominent notice on our site prior to a change of ownership or control of their personal information. If, as a result of the business transaction, your personally identifiable information will be used in a manner materially different from that stated at the time of collection, you will be given a choice consistent with our Notification of Changes section.
This site may contain links to and portions of other sites. RWR is not responsible for the privacy practices or content of these other sites. When you leave our site or view a portion of a third party’s site through our site, we encourage you to read the privacy statements of each such site. This privacy statement applies solely to information collected by RWR.
Wherever your personal information may be held within RWR or on its behalf, we intend to take commercially reasonable and appropriate steps to protect the personal information that you share with us from unauthorized access or disclosure. However, given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your information. We use encryption to protect sensitive information online. The servers that store your personally identifiable information are housed in a secure environment. Finally, we also make an effort to protect your information off-line.
When registering for access to a secure area of the site, we may ask you to select a username and password. We recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also, remember to sign out of the registered site and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence when accessing your computer.
Correcting, Updating, Deleting and Deactivating Personal Information
If your personally identifiable information changes, you may contact us to correct, update or delete and deactivate our record of your personally identifiable information.
Notification of Changes
RWR may edit this policy from time to time. If we make any substantial changes, we will prominently post a notice on the main page and other pages to alert you of the change.
Your California Privacy Rights
California Civil Code Section 1798.83 permits customers who are California residents to request that RWR not share their personal data with third parties for such parties’ direct marketing purposes. To make such a request, send an e-mail with “California Privacy” in the subject line to email@example.com write to us at the address listed below.
European Union Data Subject Rights
The General Data Protection Regulation (“GDPR”) provides certain rights for customers who are located in the European Union. RWR endeavors to enable all of these rights, including in certain circumstances, the right to withdraw consent to the processing of your personal information held by us, to request access to your personal information held by us, and the right to request erasure or transfer of your personal information held by us.
To exercise such rights, please send an e-mail with “EU Data Subject Rights” in the subject line to firstname.lastname@example.org or write to us at the address listed below.